The Centers for Medicare & Medicaid Services (CMS) has announced the CY 2026 Medicare Physician Fee Schedule (MPFS) proposed rule. If approved, these updates will take effect on January 1, 2026, bringing significant changes that will impact physical therapy billing and reimbursement.
At Trust Medus, we offer rehab therapy billing services and outsourced RCM solutions designed to help practices remain compliant and financially strong. Here’s what physical therapy clinics should know.
1.Payment Updates: Dual Conversion Factors
For the first time, CMS proposes two conversion factors (CFs):
- APM-Qualified Providers: $33.59 (+3.83%)
- Non-APM Providers (most PTs): $33.42 (+3.32%)
Impact: Even with CF increases, CMS projects small net decreases in PT reimbursement due to RVU adjustments. Some CPT codes may increase in value, while others decline.
2.RVU Efficiency Adjustments
CMS proposes a –2.5% efficiency adjustment on the intraservice portion of non-time-based codes. For PTs, this could mean reduced payments on certain services despite the conversion factor bump.
As your trusted medical billing partner, Trust Medus can deliver a CPT impact analysis to help determine where your practice revenue may be vulnerable and guide you in adapting to upcoming reimbursement changes.
3.Easier Remote Therapeutic Monitoring (RTM)
CMS proposes expanding RTM opportunities:
- Billable with 2–15 device days (instead of 16+) per 30-day period
- Management time reduced to 10 minutes/month (from 20)
Opportunity: RTM provides physical therapists with a new source of revenue while enhancing patient engagement and outcomes. Our revenue cycle management services make sure these claims are accurately submitted and reimbursed without delay.
4.Practice Expense (PE) Methodology
Proposed PE changes may shift reimbursements:
- Office-based PTs could benefit from better overhead allocations
- Facility-based PTs may see cuts in indirect PE RVUs
5.Documentation & Telehealth
- KX Modifier: Stronger emphasis on medical necessity documentation. Practices should refine workflows to reduce denial risk.
- Telehealth: CMS plans to simplify the Telehealth Services List and extend certain flexibilities, but permanent approval for therapy telehealth will remain uncertain until the final rule is released.
Action Steps for PT Practices
- Review top CPT codes for potential reimbursement impact
- Add RTM services to diversify revenue
- Strengthen documentation workflows for KX compliance
- Optimize for non-facility payment advantages
- Stay tuned for the final rule in November 2025
Final Thoughts
The CY 2026 CMS MPFS proposed rule presents both challenges and opportunities for physical therapists. By planning ahead, PTs can adjust to payment changes, leverage new RTM revenue, and maintain full billing compliance.
At Trust Medus Medical Billing, our team provides:
- Specialized rehab therapy billing services for PT, OT, and SLP clinics
- Outsourced RCM services to minimize denials and improve collections
- CPT impact analysis to prepare your practice for 2026
- Reporting and analytics to keep your finances transparent